Amayo v. Amayo, 301 Ga. 660

Wife and Husband divorced after a jury trial on April 5, 2016; both filed cross-motions for attorney fees.
The trial court awarded Husband $1,080 under OCGA § 9-15-14 (abusive litigation statute) and $15,000 under OCGA § 19-6-2.
The trial court did not make written findings identifying the specific abusive conduct or indicate whether the award was under subsection (a) or (b) of OCGA § 9-15-14.
Wife appealed; the Supreme Court granted discretionary review and directed briefing on whether the § 9-15-14 award required express findings identifying the abusive conduct.
The Supreme Court concluded the trial court erred for failing to make required findings and vacated the $1,080 § 9-15-14 award, remanding for reconsideration.
The Court declined to address additional challenges to the § 19-6-2 award because they were beyond the specific issue presented for review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the § 9-15-14 fee award is valid without express findings identifying abusive conduct	Amayo (Wife) argued the award is invalid because the trial court failed to specify the abusive conduct and whether it acted under subsection (a) or (b)	Amayo (Husband) implicitly defended the award as proper (court record shows fee granted)	Court held the award must be vacated and remanded because required express findings were not made

Williams v. Becker, 294 Ga. 411 (affirming requirement that courts making § 9-15-14 awards specify the abusive conduct and statutory subsection)
McKemie v. City of Griffin, 272 Ga. 843 (establishing that fee awards under § 9-15-14 require express factual findings; lack of findings mandates vacatur)
Ga. Dept. of Transp. v. Douglas Asphalt Co., 295 Ga. App. 421 (noting courts must state whether § 9-15-14 awards are under subsection (a) or (b))